This document outlines how Restitution Impact limited processes and manages personal data and:

• Identifies the data controller.
• Explains the lawful basis for processing personal data.
• Outlines the personal data held and processed.
• Outlines the scope of the special category personal data held and processed.
• Outlines the process of Subject Access Requests.

1. DATA CONTROLLER

The Data Controller is Restitution Impact limited

2. CONTACT

If you have any questions about this policy or for more information about how we use your data or would like to exercise any of your rights contact Restitution Impact limited. by any of the methods set out below.

3. LAWFUL BASIS FOR PROCESSING

All processing is carried out by consent, under the legitimate interest of Restitution Impact limited, or public interest.  These cover processing to conduct casework, campaigning, advertising, marketing and communication.  Where processed under the lawful basis of a task carried out in the public interest, it is to support or promote engagement, including fundraising activity in order to support engagement.

Processing may also be carried out for one or more of the purposes set out in the following table:

4. DATA SOURCES

Data held is that provided by you when you contact us and correspondence with third parties in response to cases taken up on your behalf. You may also provide data to us if you interact with us on social media such as Facebook or Twitter, and in such case you should consult the privacy terms and options for those services.

5. DATA SECURITY

Personal data is stored electronically and securely. We ensure that our service providers comply with the same high standard that we do, and are in the UK. We also have policies and procedures in place to deal with the unlikely event of a data breach.

6. TRANSFERRING YOUR DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA

Some service providers are located outside of the European Economic Area (EEA) and therefore it may be necessary to transfer your personal data outside of the EEA. Where

the transfer of your data outside of the EEA takes place we will make sure that it is protected in the same way as if the data was inside the EEA, and it only occurs with your consent.

We will use one of the following safeguards to ensure this:

• Where the European Commission has issued an adequacy decision determining that a non-EEA country or organisation ensures an adequate level of data protection.
• A contract is put in place with the recipient of the data obliging them to protect the data to the same standards as the EEA.
• The transfer is to an organisation that complies with the EU-US Privacy Shield.

Legally it is not permitted to transfer certain types of data, such as Electoral Register Data, outside of the EEA, and we honour that obligation.

7. DATA RETENTION POLICY

Personal data will be held for no longer than necessary. Some types of data may be held for longer than others. Typically the maximum retention is 5 years. Review of the data held will occur at that time to determine whether it should be maintained or put beyond use.

8. SUBJECT ACCESS REQUESTS

Subject Access Requests are dealt with in line with the guidance given by the Information Commissioner’s Office (ICO):

• We will request verification of the identity of any individual making a request, and ask for further clarification and details if needed.
• We will respond within one month once we have confirmed it is a legitimate request.
• Data subjects have the right to the following:
  • To be told whether any personal data is being processed
  • To be given a description of the personal data, the reasons it is being processed and whether it will be given to another organisations or people.
  • To be given a copy of the information comprising the data, and given details of the source of the data where this is available.

9. WILL WE SHARE YOUR DATA WITH ANYONE ELSE?

If you have contacted us about a personal or policy issue, your data may be passed on to a third-party in the course of dealing with your enquiry, such as local authorities, government agencies, public bodies, health trusts, regulators, and so on. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only for the basis upon which they were originally intended. We only share your data with a third party if required to do so by law.

Data may also be shared with entities of Political Party associations, federations, branches, groups and affiliates in order to assist you or maintain contact with you in support of democratic engagement, where they are affiliated with our client who is the data controller. Your personal data is only used as outlined here and within your reasonable expectations based on the nature of the communication, and recognising the need of politically related engagement in wider support of democratic engagement.

10. COOKIES

Cookies are small text files placed on your device when you visit our website. They allow us to make the website easier to use, to provide you with a more personalised experience, to guard against malicious activities and to ensure any login feature functions correctly. They do not collect personal information about you.

You can remove or block cookies by changing the settings in your browser, but the functionality of the website may be adversely affected.

By using our website, you are consenting to our use of cookies in accordance with this notice. If you do not agree to our use of cookies then we advise you to set your browser settings accordingly. You can find out more about cookies at www.allaboutcookies.org.

11. OTHER WEBSITES

Our websites will contain links to other websites not under our control. As such, we cannot be responsible for the protection and privacy of any information you may provide while visiting other websites, nor are those websites governed by this privacy policy. If you have any concerns please refer to the privacy policy of the website in question.

12. CUSTOMISED ADVERTISING

We use advertising to show advertisements on various websites as well as advertisements on search engine results pages. This drives traffic to our website, but also enables us to show specific advertisements to users who have visited our website. Information about how Google uses personal information for ad personalisation is available here, and you can manage your preferences of advertisement personalisation by following the steps set out here. Information about advertisement preferences on Facebook can be found here, and for Twitter here.

13. DATA RIGHTS

At any point you have the following rights:

• Right of access – you have the right to request a copy of the information held about
• Right to withdraw consent – where we rely on your consent as the legal basis for processing, you can withdraw that consent at any time.
• Right of rectification – you have a right to correct data held about you that is inaccurate or incomplete.
• Right to be erasure – in certain circumstances you can ask for the data held about you to be erased from our records.
• Right to object – you have the right to object to certain types of processing, such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
• Right to data portability – the right in certain circumstances to request that we transfer personal data held to another organisation.

14. MAKING A COMPLAINT

If you are unhappy with the way that we have processed or handled your data then you have a right to complain to the Information Commissioner’s Office (ICO). The ICO is the supervisory body authorised by the Data Protection Act 2018 to regulate the handling of personal data within the United Kingdom. The contact details for the ICO are:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF

Telephone: 0303 123 1113

Website: https://ico.org.uk/concerns/

If you have any questions about the data held please contact our Data Protection Officer,

at:  Restitution Impact Limited, 3rd Floor, 207 Regent Street, London, W1B 3HH.

Email:  ear@restitution.org.uk

Please note that proof of identity is required should you choose to exercise any of the above rights in relation to personal data.

We retain the right to update this policy at any time. If there are changes that significantly impact your rights, we will contact you in advance.