MIDDLE EAST MEDIA – GENERAL PRIVACY NOTICE

Last updated 14th June 2023.

1. About us and how to contact us

The website at www.mem.org (our website) is provided by Middle East Media (“we, “us”, “our”, “MEM”). We are a charity registered with the Charity Commission for England and Wales under registration number 271373. 

We are the controller of personal data collected via our website. This means we decide how your personal data is processed and for what purposes.

Our Data Protection Officer is James Baldock. You can contact him at james@mem.org or by writing to:

James Baldock (DPO)
Unit 142, 23 King Street
Cambridge
CB1 1AH
United Kingdom

2. About this privacy notice 

Please read this privacy notice carefully. It contains important information about how and why we collect and use information about you (your personal data). It also explains your rights in relation to your personal data and how to contact us or the regulator if you have a complaint. 

When we collect or use your personal data, we are subject to the UK General Data Protection Regulation (UK GDPR). 

2. How do we collect personal data about you?

We collect your personal data when you interact with us, for example, if you:

  • Donate to us.

  • Contact us to support our charitable purposes, for example, if you offer to help with our fundraising activities or to advocate for MEM. 

  • Register for or subscribe to receive our marketing materials, such as publications or information about our events. 

  • Register for or attend one of our events in person or online.

  • Interact with any of our social media accounts on Twitter, LinkedIn, Facebook or Instagram (depending on your privacy settings). 

  • Correspond with us, for example, by email or via the webform on our website. 

  • Visit our website. Our cookie policy – available at mem.org/cookie-policy – explains more about our use of cookies and similar technologies.

  • Get referred to us by a current supporter.

  • Are named on a purchased list of Trusts as the contact person, or through online research.

  • Apply for a job with us or apply to volunteer with us.

We may also receive your personal data:

  • If you have made a donation to us via a third-party organisation, such as Stewardship, CAF, Facebook, a Trust or like-minded organisation.

  • From other members of the MEM family of organisations. These are: Middle East Media USA.

If you apply to work or volunteer with us, we may receive your personal data from recruiters and your referees. We also collect and use information from your application form or CV and information that you provide during interview.

3. What type of personal data do we collect and use?

We collect and use the following types of information:

  • Name

  • Postal, residential address and/or billing address

  • Email address

  • Phone number

  • Past donations

  • Past correspondence

  • Past events that you registered for, or attended

  • In rare cases – for example, if you choose to join one of our prayer meetings – the information we collect about you may reveal your religious beliefs. Under UK GDPR, this type of information is “special category” data. 

If you make an online donation to us, we collect and use the following types of information: personal information that you voluntarily provide, such as name, email, postal address, phone number, and marketing preferences. We use Beacon CRM for our donation forms that record this information for us and store it securely, as well as using Stripe as a payment processor.

When you visit our website, we collect the following information about your activity on our website (browser data):

  • Your IP address

  • The type of browser you are using

  • The type of device you are using

  • The operating system you are using

  • Information about how you interact with our website, including the pages you have visited on our website.

If you apply to work or volunteer with us, we collect information about your: 

  • Education, qualifications, skills, and experience

  • Employment history

  • Age

  • Salary and benefits

  • National insurance details

  • Nationality and immigration status

  • Interests

  • Religious beliefs.

4. What do we use your personal data for?

We process your personal data to:

  1. Administer records of your support for MEM;

  2. Process any donation you make, and related Gift Aid; 

  3. Let you know about news, events, activities and services from MEM. Section 6 explains in more detail how we use your personal data for marketing purposes. Section 7 explains how you can let us know if you do not want to receive our marketing communications;

  4. Administer an online or in person event that you register for and/or attend;

  5. Ensure our website content is presented to you in the optimal way for display on your device;

  6. Process your job application or your application to volunteer with us (if applicable);

  7. Administer and improve our website;

  8. Respond to communications from you;

  9. Maintain our own accounts and records;

  10. Manage and coordinate the internal administration of MEM and other members of the MEM family of organisations; 

  11. Serve you ads about MEM on websites such as Facebook and Google;

  12. Identify supporters who may be able to make significant donations in line with their interests, to ensure that any such requests made are appropriate. In order to do this, we may from time-to-time access publicly available information about you (e.g., Companies House records, business websites, and LinkedIn). You can opt out of your data being used for research at any time or ask for an explanation of what we do by contacting our Data Protection Officer, whose contact information is in Section 1.

We will only process your personal data where we have a lawful basis to do so. The lawful basis we rely on depends on the type of personal data and the reason for our processing. The lawful bases we rely on are:

  • Where you have given your consent;

  • To comply with our legal and regulatory obligations;

  • For the performance of a contract with you or to take steps at your request before entering into a contract;

  • For our legitimate interests or the legitimate interests of a third party. 

A legitimate interest is when we have a justifiable reason to use your personal data, as long as this is not overridden by your rights andinterests. To balance our interests against yours, we will carry out an assessment when relying on legitimate interests. You can obtain details of this assessment by contacting us using our details in the Section above called “About us and how to contact us”. Our legitimate interests are:

  • Promoting and furthering our charitable purpose;

  • Internal administration of MEM and other members of the MEM family of organisations;

  • Auditing MEM and other members of the MEM family of organisations;

  • Statistical analysis to help us understand our donor and supporter base;

  • Administration of online and in-person events;

  • Any restructuring of the MEM organisation.

Where we process special category data – for example, personal data that reveals your religious beliefs – the lawful bases we rely on are: 

  • Explicit consent 

  • Employment, social security or social protection law, or a collective agreement.

5. What if we want to process your personal data for a new purpose?

If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will provide you with a new notice before we start processing your personal data for the new purpose. The new notice will explain this new use and will set out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

6.  When will we contact you for marketing purposes 

Email or SMS marketing: We will only contact you by email or SMS for marketing purposes if you have given consent or if the law allows us to do so without consent.

Telephone: We may contact you by phone for marketing purposes, unless you are registered with the Telephone Preference Service (TPS) or Corporate Telephone Preference Service (CTPS).

Post: We may send you marketing material by post, unless you have registered with the Mail Preference Service (MPS).

We comply with the Fundraising Code administered by the Fundraising Regulator in the United Kingdom.

7. How to tell us you do not want to receive marketing communications

We will not send you marketing material or contact you for marketing purposes if you have told us that you do not want us to. 

You can tell us that you do not want to receiving marketing materials or communications from us by any of the methods below.

If you have previously given consent to us using your personal data for direct marketing purposes, you can withdraw your consent at any time by any of the methods below:

  • Emailing us at comms@mem.org;

  • Writing to us at Unit 142, 23 King St. Cambridge, CB1 1AH, United Kingdom;

  • Using the “unsubscribe” link at the bottom of any email that we have sent you.

8. How to withdraw your consent to our use of your personal data

If you previously gave your consent for us to use your personal data for any purpose, you can withdraw your consent at any time. You can do this by contacting us via any of the methods described in Section 7 of this Privacy Notice.

9. Third party websites

Our website may contain links to other websites owned or operated by third parties. Those third party websites may also collect your personal data in accordance with their own privacy policies. For information relating to those third party websites’ use of your personal data, please consult their privacy policies.

10. Sharing your personal data

We may share your personal data with:

  • Other members of the MEM family of organisations. These are: MEM USA, PO Box 4949, Wheaton IL, 60189-4949 USA;

  • Our external auditors and professional advisers (for example, our lawyers);

  • Service providers we use to help run our organisation, including website hosts and website analytics service providers;

  • External providers of fundraising support services;

  • Law enforcement agencies.

If we undergo a restructuring, a third party may acquire control or ownership of our assets or may take over our operations. In these circumstances we may share your information with the relevant third party.

11. When might we transfer your personal data outside of the UK?

It may sometimes be necessary for us to transfer your personal data to countries outside the United Kingdom, for example:

  • When our service providers are located outside the United Kingdom;

  • When we share your personal data with other members of the MEM family of organisations.

Many countries do not have the same data protection laws as the United Kingdom. We will, however, ensure that when we transfer your personal data to a country outside the United Kingdom, the transfer complies with UK GDPR. For instance, we may put in place regulator approved standard contractual clauses with a third party outside the UK, and carry out a risk assessment to ensure that your personal data has sufficient protections in the third country.

12. How long do we keep your personal data?

We will not keep your personal data for longer than we need it for the purpose for which it is used.

For example, we will retain details of donations to meet tax and accounting requirements (6 years).

Legacies are an important way that many supporters choose to remember the work of MEM in the Middle East. We may keep data you provide indefinitely to carry out the administration of legacies – sometimes we have to prove how long someone has supported MEM and to communicate with the families of those leaving us legacies. The data that will be retained for administering legacies will be the name, most recent address, and donation history. This data will relate only to the deceased person.

13. Your rights in relation to your personal data

This section contains a short summary of your rights in relation to your personal data. These rights do not apply in every situation. For further information, including the circumstances in which they do and do not apply, you may find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under UK GDPR. The rights are:

  1. The right to ask us for a copy of your personal data which we hold about you.

  2. The right to ask us to correct any of your personal data that is inaccurate or out of date. You also have the right to ask us to complete information that is incomplete.

  3. The right to ask us to erase your personal data where it is no longer necessary for us to retain it.

  4. The right to request a restriction on processing of your personal data in certain circumstances, for example, if you contest the accuracy of your personal data.

  5. The right to receive the personal data you provided to us, in a structured, commonly-used, machine readable format and/or transmit that data to a third party, in certain circumstances.

  6. The right to withdraw your consent to processing of your personal data at any time. Please see Section 8 of this Privacy Notice for further details.

  7. The right to object to the processing of your personal data for direct marketing purposes.

  8. The right to object to the processing of your personal data in certain other circumstances.

  9. The right to lodge a complaint with the Information Commissioners Office.

14. Complaints

Please contact us if you have any concerns about our use of your personal data. See Section 1: “About us and how to contact us”. We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the UK’s Information Commissioner. You can contact the Information Commissioner on 0303 123 1113 or using the details at https://ico.org.uk/make-a-complaint/.

15. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. If we make significant changes to this Privacy Notice, we will take steps to inform you, for example, by email or by including a prominent link to a description of the changes on our website for a reasonable period. 

The date at the top of this privacy notice tells you when this Privacy Notice was last updated.