Charity means Transform Justice, a registered charity.
GDPR means the General Data Protection Regulation.
Responsible Person means Penelope Gibbs, Director, Transform Justice.
Register of Systems means a register of all systems or contexts in which personal data is processed by Transform Justice
1. Data protection principles
Transform Justice is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
2. General provisions
- This policy applies to all personal data processed by Transform Justice.
- The Responsible Person shall take responsibility for Transform Justice’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
3. Lawful, fair and transparent processing
- To ensure its processing of data is lawful, fair and transparent, Transform Justice shall maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually.
- Individuals have the right to access their personal data and any such requests made to Transform Justice shall be dealt with in a timely manner.
4. Lawful purposes
- All data processed by Transform Justice must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests
- Transform Justice shall note the appropriate lawful basis in the Register of Systems.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Transform Justice’s systems.
5. Data minimisation
- Transform Justice shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- This involves deleting any data over five years old.
- Transform Justice shall take reasonable steps to ensure personal data is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
7. Archiving / removal
- To ensure that personal data is kept for no longer than necessary, Transform Justice shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
- The archiving policy shall consider what data should/must be retained, for how long, and why.
- Transform Justice shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Transform Justice shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
Transform Justice may use standard technology called ‘cookies’ on this site. Cookies are small bits of information that are stored by your browser on your computer’s hard drive. We do this to understand your use of our services, improve your user experience and enable personalised features and content and optimise our marketing. Most browsers automatically accept cookies, but you can usually change your browser to prevent cookies being stored. However, if you do turn cookies off, this will limit the service provided to you.
10. Facebook pixel
Facebook Pixel allows Facebook to identify the visitors of our online content as a target group for displaying advertisements (known as “Facebook ads”). Accordingly, we use Facebook Pixel to display our posted Facebook ads only to Facebook users who have shown an interest in our services or who share certain factors (such as interests in certain topics or products determined on the basis of visited web pages), which we transmit to Facebook (which is known as Custom Audiences). Facebook Pixel also helps us understand the effectiveness of Facebook ads for statistical and market research purposes, by showing whether users have been redirected to our services after clicking on a Facebook ad (known as conversion, and allowing to determine on which devices a user is performing an action), in order to create so-called lookalike audiences or statistical twins (i.e. to broadcast ads to target groups that are similar to existing customers) and to obtain comprehensive statistics about the use of the website. Facebook Pixel establishes a direct connection to the Facebook servers when you visit our website. This way, the Facebook server is notified that you have visited our website and Facebook assigns this information to your personal Facebook user account.
For further information about the collection and use of data by Facebook and your privacy protection rights and options, please see the Facebook data protection policy at https://www.facebook.com/