What is Data Protection?
Simply put, data protection is about protecting people from the misuse of their personal information.
ROLDA’s Data Protection Policy is designed to ensure the charity’s compliance with the US current laws, the General Data Protection Regulations (GDPR) and the Privacy and Electronic Communications Regulations (EC Directive)(Amendment) 2011.
This statement explains the data protection practices which apply to https://rolda.org and all its subdomains (“Site”) operated by the Romanian League in Defense of Animals, Inc, ROLDA USA or “ROLDA” (EIN 32-0176929) and to its affiliates: Fundatia ROLDA in Romania, ROLDA Gatehunder fra Romania in Norway, Association ROLDA Suisse in Switzerland, Association ROLDA Sverige in Sweden, ROLDA, Inc in Australia, ROLDA UK in England and Wales, as part of the ROLDA project.
In this Policy references to ROLDA or to “we” or “us” are to all these parties (Fundatia ROLDA, Gatehunder fra Romania, Association ROLDA Suisse, Association ROLDA Sverige, Romanian League in Defense of Animals, Inc, ROLDA, ROLDA UK) together.
What the Law says about the protection of personal information
The Law on Data Protection is derived from various pieces of legislation (can be found in a number of places). These include the Data Protection Act and the incoming General Data Protection Regulation (‘GDPR’) which became enforceable in May 2018. The GDPR states that personal data (information relating to a person that can be individually identified) can only be processed if there is a legal ground to do so. Activities like collecting, storing and using personal information would fall into the GDPR’s definition of processing. The GDPR provides six legal grounds (reasons) under which personal information can be processed (used) in a way that is lawful. For the processing to be permitted by law (lawful), at least one of the legal grounds must apply.
The four legal grounds that are most relevant to ROLDA’s use of your personal information are:
- Legitimate Interest
- Legal Obligation
How the law applies to ROLDA’s use of personal information
ROLDA will only process (use) your personal information if we have:
– asked you and have a record of your express and recent consent for us to do so;
– a ‘Legitimate Interest’ to do so in order to support our charitable purposes. Our use will be fair and balanced and never unduly have an impact on your rights.;
– a contract with you that we can only fulfill by using your personal information, e.g. a dog adoption contract or a contract to send you an item that you have requested;
– a legal obligation to use or disclose information about you
We will not unduly prioritize our interests as a charity over your interests as an individual. We will always balance our interests with your rights. We will only use personal information in a way and for a purpose that you would reasonably expect in accordance with this Policy.
ROLDA will not rent, swap or sell your personal information to other organisations for them to use in their own marketing activities.
ROLDA will always ask for your consent before we communicate with you for certain purposes. For example, we will only email or phone you about our fundraising activities if we have an accurate record of your recent and freely given consent to do so.
You can withdraw your consent at any time by emailing email@example.com
There are times when it is not practical to obtain and record consent. At those times, we will only process personal information if that processing would meet another legal ground e.g. Legitimate Interests, in which case we would only process in accordance with the law’s strict rules on legitimate interest processing.
What is Legitimate Interest
This legal ground for processing means that organizations can process your personal information if they:
1. Have a genuine and legitimate reason for doing so and
2. That use does not harm any of your rights and interests as an individual.
ROLDA’s Legitimate Interest
We do not unduly prioritize our legitimate business interests as a charity over your interests as an individual. We always respect your rights. This is why we carry out a balancing exercise of the rights of the charity with the rights of our supporters.
We believe that the best way to look after the interests of our supporters is to consider their unique interests and expectations. As a result, we have established the following categories of ROLDA supporters. This provides us with an additional method for assessing that we use your personal information in a way that matches your relationship with us; your interests; and your expectations about your rights.
The four groups for our data protection supporter needs assessments are, supporters that have:
a) pledged their Lifetime interest
b) rehomed a dog with us
c) provided financial donations
d) demonstrated an interest in our cause by contacting us for more information, e.g. to find out more about one of our products, services or campaigns.
What we have a Legitimate Interest to do
We believe that ROLDA supporters are connected to our mission and want to know how they can continue to help us to achieve our charitable aims. Unless you tell us not to, we think you are content for us to process (keep and use) your personal information for the following lengths of time. As of May 2018, we promise not to keep your personal information for longer than we specify below. This is not the length of time that we will continue to contact you – this could be a shorter period of time.
Lifetime Interest in ROLDA
For supporters who have indicated a Lifetime interest in ROLDA by pledging to leave us a gift in your will – we need to keep your information to ensure that your wishes are fulfilled.
These are supporters that rehomed a dog from ROLDA and on average a dog lives to the age of 16 years old. We think that you and the dog you rehomed from us would like to remain in contact with us throughout their lifetime and we will therefore keep your personal information to allow for this.
Financial Supporters of ROLDA
These are supporters that help or have helped us with financial gifts. A supporter’s pattern of giving can often change over time. We have found that our financial supporter’s cycle of giving is on average 6½ years. That means the supporter may, for this period of time, stop providing financial support e.g. stop regular giving through Sponsor A Dog. This can be for a wide number of reasons, including because they choose to support us in a different way. Irrespective of their financial circumstances, these supporters still hold the same principles and values; and continue to be connected to ROLDA and our mission.
This is evidenced by the fact that many of this group of supporters restart regular-giving, and other financial support, within 6½ years of their last donation. We believe that supporters of our mission never stop believing in the importance of improving the lives of dogs, but we do stop using the personal information of these supporters after 6½ years from the time of the last donation.
Demonstrated interest in ROLDA via an inquiry
These are supporters of our mission, who have demonstrated an interest in our cause by contacting us for more information, e.g. to find out more about one of our products, services or campaigns.
We think someone that has reached out to us to find out more about ROLDA and what we do, would like us to provide that information; perhaps a little more information; and even some support in fulfilling their initial query or request. To support this, we keep your personal information for a period of 2 years.
Supporters demonstrate their support in a number of ways and so could be in more than one, or even all, of the above categories. We will review and refresh these categories and the timescales on a rolling basis to ensure that as times and needs change we continue to do the very best for our supporters.
It is always your choice. If you don’t think this is quite right for you, you can tell us to change your communication preferences and our use of your information. You can do this at any time by emailing firstname.lastname@example.org
Legitimate Interest to send you direct mail
Unless you tell us not to, we will rely on our Legitimate Interest ground (explained above) for sending you direct mail. From time to time, we would like to post you exciting updates about our work, products, services and how you can support us, including fundraising activities and research. Unless you have requested that we do not send you some, or all of this, our direct mailings do include marketing and fundraising ask that further the aims and objectives of ROLDA.
We are always mindful of trying to only send you what you are interested in and only as often as is appropriate. If we do not appear to be sending communications that are of interest, we will review this and will endeavor to reduce and then stop these types of communications in a much shorter time than the above-defined period of Legitimate Interest e.g. if you donated three years ago and do not seem to have been interested since then we are likely to reduce these communications, even though we have a legitimate interest to process for 6 ½ years. The average length of time required for us to be able to properly assess and reflect on your pattern of response is about two years. But you’re in control so if you want to ensure that we do not send this type of communication anymore, you can update your preferences at any time by emailing us at email@example.com
Legitimate Interest to process your information
We aim to be clear about what information we collect, to enable you to make meaningful choices about how it is used.
When it is necessary we will contact you for administrative purposes, e.g. to contact you regarding a payment. We will also hold the minimum personal information required to support our ability to respect your preferences for communication with us.
To help you to understand when and why ROLDA would use Legitimate Interest to process your personal information we provide the following examples:
- To send postal communications (as explained above).
- To enhance, modify, personalize and improve our services and communications for the benefit of our supporters.
- To improve the security of our websites and systems.
- To prevent fraud when transacting on our website.
- To process your donations.
- To fulfill online transactions; process and deliver your order(s).
- To take payment and arrange delivery, we need to collect personal information, including your payment details, your full name, delivery address and contact details.
- To analyze your personal information to ensure that our communications are relevant to you.
The above list of examples is on the basis that the processing will not be done if it harms your rights and interests as an individual, or if you tell us that you’d like us to stop. You can do this at any time by emailing firstname.lastname@example.org.
Data Protection Officer (DOP) Elena Daniela Costin
Address: PO Box 4674, Crofton MD 21114 – USA
Registered as a 501(c)(3) non-profit organization in California state
Phone 410-353-5505 (US) or 004 0748903612 (Romania)